The Tax Administration and Customs Administration are required to remove from their balance sheets all business debts created before December 31, 2014.
The General Directorate of Taxes has announced that businesses with unpaid liabilities from 2015 to 2024 will be able to begin installment payments starting June 10.
According to the official announcement, within 20 days from the entry into force of the instruction, a full list will be prepared of entities benefiting from the cancellation of tax liabilities, as well as those that do not qualify. Taxpayers will be notified electronically through the “e-Filing” system.
After the completion of this process, the Tax Administration will continue with the automatic offsetting of VAT credit surpluses or other tax credits against the existing liabilities of businesses.
Categories of Liabilities Eligible for Cancellation/Relief
1. Tax liabilities up to December 31, 2014
All unpaid tax liabilities related to tax periods up to December 31, 2014, including fines and late payment interest, will be fully cancelled. However, the principal obligations for social and health insurance contributions will not be forgiven.
2. Tax liabilities for the period January 1, 2015 – December 31, 2019
- 50% of the principal liability will be cancelled if the remaining 50% is paid in a lump sum between June 10, 2026, and June 30, 2026;
- 25% of the principal liability will be cancelled if the remaining 75% is paid between June 10, 2026, and December 31, 2026.
In both cases, fines and late payment interest will be fully cancelled.
3. Tax liabilities for the period January 1, 2020 – December 31, 2024
Fines and late payment interest will be cancelled on the condition that the full tax amount (100% of the principal) for the relevant period is paid between June 10, 2026, and December 31, 2026.
Other Benefits Provided by Law
According to Law No. 86/2025:
- Liabilities will be cancelled for entities deregistered at the National Business Center (QKB) or by court decision before December 31, 2024, except for social and health insurance contributions;
- Fines for non-declaration or delayed declaration related to periods up to December 31, 2024, will be cancelled, provided that the missing declarations are submitted by June 30, 2026;
- Fines for late submission of financial statements and decisions regarding profit allocation calculated up to December 31, 2024, will be cancelled;
- Fines and interest resulting from payroll changes due to retroactive legal/sublegal acts or final court decisions will be cancelled;
- Administrative fines for periods up to December 31, 2024, will also be cancelled.
Entities That Do Not Benefit
The following entities are excluded from benefiting from the cancellation or relief measures:
- Entities convicted by a final court decision for criminal offenses in the field of taxation and/or customs;
- Entities currently under judicial process or investigation for tax and/or customs criminal offenses during the implementation period of the law;
- Entities against which there is a final court ruling in favor of the Tax or Customs Administration regarding liabilities subject to relief.
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